Our Code of Conduct

Ziklo Bank conducts its business in an industry where increasing demands are placed on trust and transparency. Regardless of our job description within the bank, we are committed to acting in a way that fosters trust and respect among customers, partners, owners, authorities, and other stakeholders.

Our code of conduct emphasizes accountability and professionalism. It serves as a guide and framework for all employees on how to behave at work. The strongest guiding light, however, is each employee’s common sense – and the moral compass that helps us distinguish between right and wrong. Personal responsibility is a matter of pride at Ziklo Bank.

The code of conduct applies to all who represent Ziklo Bank, including consultants and independent contractors.

We take banking confidentiality very seriously 

All information about our customers is confidential. This includes information on an existing or past relationship between us and a customer, or discussions about potentially becoming a customer. Details protected by confidentiality include names, addresses, accounts, services, products used by the customer, and family relationships. Naturally, we never disclose or discuss confidential information with anyone who lacks the proper authorization, including colleagues. Nor do we discuss sensitive matters or disclose confidential information outside Ziklo Bank.

By knowing our customers we can prevent money laundering and terrorism financing 

We always need to know our customers’ identities. For legal entities, this means identifying the principal owner and decision-maker. We only enter into a business relationship if we understand the customer's business – and if it is legitimate. We continuously monitor ongoing business relationships ensuring that transactions align with what is known about the customer in question. Furthermore, we screen official lists of individuals and organizations potentially linked to money laundering and terrorist activities. If we detect suspicious activities, we alert the relevant authorities without delay.

We protect your personal data

We have stringent procedures in place for handling and protecting personal data. We may only collect and use personal data if it is necessary for specific legal purposes, such as fulfilling a contract, or in the case of a legitimate interest. Beyond that, the customer needs to provide consent. Customers should be informed on how we intend to handle their personal data when we collect the information. Generally speaking, personal data should only be used for its original purpose. At Ziklo Bank, employees may only access personal data if it is a requirement for performing authorized tasks.

We identify and handle conflicts of interest 

As employees, we are loyal to our employer and to our customers. In our professional roles, we prioritize the interests of the employer and customers. A conflict of interest arises when business or personal relationships affect professional judgement and the capacity to act in the best interests of Ziklo Bank and its customers. In each business decision, or during customer interactions, the interests of the customer and Ziklo Bank take precedence. All customers should be treated equally. We must be able to identify and manage conflicts of interest so that personal or professional relationships do not negatively impact the interests of the bank or the customer. An employee who identifies a potential conflict of interest should consult with their immediate supervisor or the Compliance Officer in order for the necessary counter-measures to be set in motion. A conflict of interest occurs when a decision-maker is assumed to be biased in a given situation, which may result in a conflict of interest. The lack of objectivity may, for example, originate from interest, family ties or role, depending on the specific situation. If a conflict of interest arises in a situation where you, as an employee, are the intended decision-maker, you should always refrain from making the decision.

We follow the rules for gifts, hospitality and bribes 

Ziklo Bank neither engages in nor condones illegal or unethical business practices like bribery. Bribery refers to payment or other perks intended or reasonably expected to influence how a person performs their duties. The bank adheres to rules and codes related to bribery, gifts and hospitality – and we unequivocally oppose all forms of corruption. As a bank, we apply restraint regarding the giving and receiving of gifts and perks. It is not permitted to accept gifts or allow oneself to receive anything if there is suspicion of impropriety. It can be difficult to distinguish whether a gift or an invitation to an event can be classified as bribery or an acceptable part of a business relationship. If, as an employee, you feel uncertain, inform your immediate supervisor before accepting a gift or an invitation. Furthermore, you should ensure that “benefits” you give and receive have minimal value and completely avoid perks that could affect the giver’s or recipient’s behaviour on the job. A strong indicator that a gift or benefit comes with strings attached is if it is given underhandedly. Public officials may not be offered any form of gift or benefit (not even a simple sandwich) when exercising their official duties. This applies equally to gifts or benefits for individuals involved in procurement for publicly funded activities.

Fair competition 

We follow all rules governing fair competition and so-called anti-competitive practices. The rules are complex but designed to safeguard fair competition between companies. We avoid situations that can lead to anti-competitive behaviour, including:

  • Proposals from competitors to share price information, or marketing information, or to divide markets or customers.
  • Discussions on competitively sensitive subjects, including prices, pricing, costs, and marketing strategies.

We handle complaints swiftly and efficiently 

Complaints from customers provide valuable information that can form the basis for our improvement efforts. Thus complaints should be handled promptly, with a positive approach, clearly demonstrating that we listen to and take criticism seriously. We correct mistakes as soon as possible.

Discrimination and harassment have no place in our bank 

We aim to be a professional and welcoming workplace characterized by respect, integrity, and tolerance. We strongly oppose all forms of discrimination based on gender, race, skin colour, language, nationality, ethnic or social origin, genetic characteristics, belief, political or other views, affiliation with a national minority, wealth, birth, disability, age, gender, gender identity, or sexual orientation. All employees should be treated with equal respect. We also enforce a zero-tolerance policy against sexual harassment.

A good working environment is essential 

We strive to create an inspiring workplace that encourages collaboration and responsibility. Our workplace is clean, healthy and safe. We do not tolerate the use of drugs on the premises, while at the same time encouraging employees with alcohol- or drug-related issues to seek help. We promote an atmosphere in which employees do not hesitate to point out and report dubious and unethical behaviour.

We handle irregularities 

The bank should be characterized by openness, transparency and ethical conduct. A basic and obvious principle is that the bank should conduct its operations responsibly, honouring not only the regulations governing the business, but also the rules established by the bank itself. Irregularities are not tolerated. A person reporting irregularities should feel confident that the bank wants problems to be brought to light and resolved. Therefore, the bank applies a system for handling so-called whistleblowing. Whistleblowing means that one can report irregularities to the bank’s whistleblowing platform with the option to remain completely anonymous. All messages in the whistleblowing system are treated in strictest confidence. Further information on whistleblowing – and how to report irregularities – can be found here (in Swedish).

In addition to the bank's whistleblowing platform, irregularities can be reported externally too. The external channels are provided by specially designated authorities (pertaining to specific subject areas). The list of authorities that can receive reports, in addition to the subject areas, are specified in the annex to the stipulations on the protection of persons reporting irregularities (SFS 2021:949). You can find it here (in Swedish). Reports must be made via the relevant authority’s own channel. Detailed instructions on how to proceed are available on the website of the authority in question.


To us, sustainability is a key strategic issue. Ultimately, our ambition is to ensure the long-term viability of our operation – not only environmentally but socially too. Our venture should be characterized by sound internal governance and control. This work is an integral part of all our operations. Every employee has a duty to follow established procedures and guidelines.

In our pursuit of sustainability, we have chosen to focus on areas where we believe we have the greatest opportunity to reduce negative impact and create value. We have a significant responsibility for our environment – and a duty to reduce our climate and environmental impact. Energy, raw materials and other resources should be used efficiently and with respect for the environment. Environmental considerations should inform all our decisions.